Privacy Policy – HRG Trendy Shoes Company

This Application collects some Personal Data from its Users.

PRIVACY POLICY IMPORTANT: BY USING OUR SITE SERVICES, INCLUDING WITHOUT LIMITATION ANY OF ITS APPLICATIONS OR WEBSITES (THE “SERVICES”) YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT ALL PERSONAL DATA (AS DEFINED UNDER REGULATION (EU) 2016/679 (GENERAL DATA PROTECTION REGULATION) (“PII”) THAT YOU SUBMIT OR THAT IS PROCESSED OR COLLECTED THROUGH THE SERVICES MAY BE PROCESSED BY THE COMPANY IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, city, User ID, geographic position, username and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.

All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisments on this Application, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Interaction with external social networks and platforms, Analytics, Commercial affiliation, Contacting the User, Advertising, Location-based interactions, SPAM protection, Remarketing and behavioral targeting, Content commenting and Managing contacts and sending messages.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Google AdSense (Google Inc.)

Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered. Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc. In order to understand Google’s use of Data, consult Google’s partner policy. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data. Place of processing: US – Privacy Policy – Opt Out

Amazon Mobile Ads (Amazon)

Amazon Mobile Ads is an advertising service provided by Amazon.com, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Direct Email Marketing (DEM) (This Application)

This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application. Personal Data collected: email address.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out

Commercial affiliation

This type of service allows this Application to display advertisments for third party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics. Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with this Application. For details of which data are collected, please refer to the privacy policy of each service.

CJ Affiliate by Conversant (Conversant, Inc.)

CJ Affiliate by Conversant is a commercial affiliation service provided by Conversant, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

LinkShare (Rakuten Marketing LLC)

LinkShare is a commercial affiliation service provided by Rakuten Marketing LLC. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Amazon Affiliation (Amazon

Amazon Affiliation is a commercial affiliation service provided by amazon.com Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

eBay Partner Network (eBay, Inc.)

eBay Partner Network è un servizio di affiliazione commerciale fornito da eBay, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy

VigLink (VigLink, Inc.)

VigLink is a commercial affiliation service provided by VigLink, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Amazon Omakase (Amazon)

Amazon Omakase is a banner commercial affiliation service provided by amazon.com Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Company is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to www.amazon.com.

Awin (AWIN AG)

Awin is a commercial affiliation service provided by AWIN AG. Personal Data collected: Cookies and Usage Data. Place of processing: Germany – Privacy Policy

Contacting the User

Contact form (This Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: address, city, country, date of birth, email address, first name, gender, last name, User ID and ZIP/Postal code.

Mailing list or newsletter (This Application)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase. Personal Data collected: email address, first name and last name.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Application. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Comment system managed directly (This Application)

This Application has its own internal content comment system. Personal Data collected: first name, last name and username.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Twitter Tweet button and social widgets (Twitter, Inc.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Pinterest “Pin it” button and social widgets (Pinterest)

The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Google+ +1 button and social widgets (Google Inc.)

The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

AddThis (Addthis Inc.)

AddThis is a service provided by Clearspring Technologies Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of this Application. Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Location-based interactions

Geolocation (This Application)

This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application. Personal Data collected: geographic position.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Constant Contact (Constant Contact, Inc.)

Constant Contact is an email address management and message sending service provided by Constant Contact, Inc. Personal Data collected: email address. Place of processing: US – Privacy Policy

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out

SPAM protection

This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc. The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy

Further information about Personal Data

Push notifications

This Application may send push notifications to the User.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Small piece of data stored in the User’s device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This privacy policy relates solely to this Application.